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Facts

  • The case involves a dispute between Gila Regional Medical Center (Plaintiff) and Chinonyerem Osuagwu, M.D. (Defendant), regarding the premature termination of Defendant's employment with Plaintiff. Plaintiff had advanced living expenses to Defendant under an agreement that required Defendant to work as a credentialed physician for three years. Defendant left the employment earlier than agreed, leading to Plaintiff's claim for repayment of the advanced expenses. Defendant asserted Plaintiff's breach of contract, specifically failure to comply with its bylaws, as an affirmative defense (para 3).

Procedural History

  • Cause No. 31,149, July 15, 2011: The Court of Appeals reversed the district court's order granting Plaintiff summary judgment on its claim for repayment of living expenses, citing unresolved material facts and the district court's failure to rule on Defendant's motion to amend his answer to add counterclaims (para 3).
  • District Court of Grant County, (N/A): On remand, the district court granted Defendant's motion to add counterclaims but dismissed them on jurisdictional grounds. It then "reinstated" the summary judgment previously granted to Plaintiff (para 5).

Parties' Submissions

  • Plaintiff: Argued that Defendant breached the recruitment agreement by resigning his hospital privileges before completing the required three years of service, which was the basis for the advanced living expenses (para 8).
  • Defendant: Asserted Plaintiff's breach of contract due to failure to comply with its bylaws as an affirmative defense. Also, sought to file an amended answer to add counterclaims (para 3).

Legal Issues

  • Whether the district court erred in granting summary judgment to Plaintiff despite the presence of disputed material facts related to Plaintiff’s claim and Defendant’s affirmative defense.
  • Whether the district court complied with the appellate court's mandate on remand by "reinstating" summary judgment in favor of Plaintiff without holding a trial on the merits (paras 6-8).

Disposition

  • The order granting Plaintiff summary judgment is reversed (para 10).

Reasons

  • The Court of Appeals, with Judge Michael E. Vigil authoring the opinion, and concurrence from Chief Judge Roderick T. Kennedy and Judge M. Monica Zamora, found that the district court failed to comply with its mandate on remand. The appellate court had previously reversed the grant of summary judgment due to unresolved material facts concerning Defendant’s departure and whether Plaintiff complied with its bylaws. Upon remand, the district court dismissed Defendant's counterclaims on jurisdictional grounds and reinstated summary judgment for Plaintiff without addressing these material facts. The appellate court held that the presence of material issues of fact precluded granting summary judgment on Plaintiff's breach of contract claim and Defendant's affirmative defense, requiring a trial on the merits as per the appellate court's previous mandate (paras 6-8).
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